July 13th, 2015 

Great Scott Property Services Inc. 

Attn: Stanley R. Scott III 

7215 Bedlington Road 

Miami Lakes, FL. 33014 

stan@principalrealty.net 

To: 

Federal Aviation Administration 

U.S. DEPARTMENT OF TRANSPORTATION 

DOCKET MANAGEMENT SYSTEM 

1200 NEW JERSEY AVE., SE 

WASHINGTON, DC 20590 

FILED WITH www.regulations.gov

Re: Petitions for Exemption under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations 

To Whom in May Concern: 

This application is being submitted on my own behalf. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

and 14 C.F.R. Part 11, Great Scott Property Services Inc., operator of a Small Unmanned 

Aircraft Systems (sUAS) equipped to conduct aerial photography and videography for the real 

estate industry, hereby applies for an exemption from the listed Federal Aviation Regulations 

(FARs) to allow commercial operation of its sUASs, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as required 

by Section 333.1 

Great Scott Property Services Inc. requested exemption would permit the operation of sUAS 

under controlled and secure conditions that is: (i) limited, (ii) predetermined, (iii) subject to 

controlled access, and (iv) provide greater safety in connection with aircraft operations. As 

established by the exemptions already granted by the FAA, approval of Great Scott Property 

Services Inc. exemption would enhance safety and fulfill the FAA Administrator’s responsibilities 

to “...establish requirements for the safe operation of such aircraft systems in the national 

airspace system.” Section 333(c) of the Reform Act

14 C.F.R. Part 21 

14 C.F.R. 45.23 

14 C.F.R. 45.29 

14 C.F.R 61.3 

14 C.F.R. 61.23 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R. 61.133(a) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9 

14 C.F.R. 91.109(a) 

14 C.F.R. 91.119 
14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203 

14 CFR Subpart E (91.401-91.417) 

Applicant seeks an exemption from the following rules: 

. 14 C.F.R Part 21, 14 C.F.R 45.23, 14 C.F.R. 45.29, 14 C.F.R. 61.3, 14 C.F.R. 61.23, 14 C.F.R. 

1.113(a) & (b), 14. C.F.R. 61.133(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9, 14 C.F.R. 91.109(a), 14 

C.F.R. 91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151 (a), 14 C.F.R. 91.203, 14 CFR Subpart E 

(91.401-91.417) to operate commercially a small unmanned vehicle (55 lbs or less) for the 

purposes of real estate photography and videography. 

Upon receipt of the exemption, I shall obtain a Certificate of Authorization (COA) from the FAA 

Air Traffic Organization prior to conduction operation(s) in the NAS. The DJI Phantom 2 will 

never be flown in the flight path of manned aircraft. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The vehicle to be used will be the DJI Phantom 2. The operating limitations proposed by Great 

Scott Property Services Inc. provide for at least an equivalent or higher level of safety because 

operations further enhance safety of aerial image collection using conventional aircraft. 

The limitations and conditions include: 

1. The sUASs will weigh less than 55 pounds. 

2. Flights will be operated within line of sight (LOS) of a pilot and/or observer. 

3. Maximum flight time for each operational flight will be no more than 30 minutes. Flights 

will be terminated at no less than 25% battery power reserve should that occur prior to 

the 30 minute limit 

4. Pre-flight inspection would be checking batter condition/level in both the transmitter and 

UAS. A check for power lines, antennas and other overhead objects will be identified 

before flying. Wind conditions would also be monitored before flying. 

5. Stanley Scott will be Pilot in Command (PIC) with over 50 hours of flight time with the 

DJI Phantom 2. Testing, updating and programming the DJI Phantom 2 would be done 

on a monthly schedule. 

6. I am a citizen in good standing with no arrests or felonies. I am in good health and have 

a sound mind. I am a Realtor in South Florida. 

7. The intended use of the DJI Phantom 2 is to expand my independent contracting 

business by offering aerial photography to Realtors and to provide my clients with the 

best possible marketing available in South Florida. UAS aerial photography is a 

relatively new industry and entering the market at this time will provide me with a 

competitive edge to my Real Estate counterparts 

8. If the UAS loses communications with the remote controller or loses GPS signal, the 

UAS will have the capability to return to a pre-determined location within a designated 

location and land autonomously. 

Thank you for your attention. 

Best Regards, 

Stanley R. Scott III 
ANNEX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION

Stanley R. Scott III requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the DJI Phantom 2: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 

Sections 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart 

H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR § 91.203(a). Given the light weight and the 

limited operating area with its use, it is unnecessary to go through the certificate of airworthiness 

process under part 21 Subpart H in order to achieve or exceed current safety levels. 

The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and the proximity to airports and populated areas of the 

UAS involved. The UAV, operated without an airworthiness certificate, under the conditions 

proposed in the exemption, will be at least as safe, or safer, than a conventional aircraft with an 

airworthiness certificate. 

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks 

These regulations provide that each aircraft must display “N” and the aircraft’s registration 

number in letters at least 3 inches high. The aircraft must display the word “Experimental” in 

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. Given the 

small size of the DJI Phantom 2, this requirement is impossible to match. 

14 C.F.R. §61.23: Medical certificates: Requirement and duration 

Regulations provide that a person: 

1. Must hold a first-class medical certificate: 

• When exercising the pilot-in-command privileges of an airline transport pilot 

certificate; 

• When exercising the second-in-command privileges of an airline transport pilot 

certificate in a flag or supplemental operation in part 121 of this chapter that 

requires three or more pilots; or 

• When serving as a required pilot flight crewmember in an operation conducted 

under part 121 of this chapter if the pilot has reached his or her 60th birthday 

2. Must hold at least a second class medical certificate when exercising: 

• Second-in-command privileges of an airline transport pilot certificate in part 121 

of this chapter (other than operations specified in paragraph (a)(1)(ii of this 

section); or 

• Privileges of a commercial pilot certificate 
Given the size, build, limited flight area, and the return to home autopilot flight termination 

system features on the UAV, Stanley Scott believes that a person with a valid driver’s license 

can produce an equivalent level of safety. 

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations 

Regulation provides that no person may serve as a required pilot flight crewmember of a civil 

aircraft of the United States, unless that person: 

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that 

person’s physical possession or readily accessible in the aircraft when exercising the 

privileges of that pilot certificate or authorization. However, when the aircraft is operated 

within a foreign country, a pilot license issued by that country may be used. The 

regulation provides also that no person that holds a private pilot certificate may act as 

pilot in command of an aircraft for compensation or hire. 

Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in 

connection with any business or employment if: 

1. The flight is only incidental to that business or employment 

2. The aircraft does not carry passengers or property for compensation or hire 

Stanley Scott proposes that operators of the UAV should not be required to hold a commercial 

or private pilot certification. The equivalent level of safety will be achieved by having an 

operator trained UAV manufacturer, and using the integrated features of the aircraft to maintain 

a high level of safety at all times. 

14 C.F.R § 91.7(a): Civil aircraft airworthiness 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203(a)(1). Given the size and 

limited operating area associated with the aircraft to be utilized by the applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement 

for an airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and the proximity to airports and populated areas of the particular UAS. In all cases, 

an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as 

safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements 

The equivalent level of safety will be achieved by keeping a hard copy of the user manual in 

close proximity to the operator. 

The equivalent level of safety will be provided by having the UAV marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the UAV will see the 

identification of the UAS as "Experimental." The FAA has issued the following exemptions to 

this regulation to Exemptions Numbers 10700, 8738, 10167 and 10167A. 
14 C.F.R. § 91.109(a): Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." 

The equivalent level of safety during the in-flight training will be achieved by the manufacturer or 

affiliate providing the training as described in the manufacturer's training program and through 

the use of experienced and qualified instructors familiar with the UAV. 

14 CFR § 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. The exemption requests 

authority to operate at altitudes up to 400 AGL, It will however be operated in a restricted area 

with security perimeter, where buildings and people will not be exposed to operations without 

their pre obtained consent. The equivalent level of safety will be achieved given the size, weight, 

speed of the UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Compared to flight operations with aircraft 

weighing far more than those proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional 

aircraft. 

14 CFR 91.121: Altimeter settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set" ... to the elevation of the departure airport or an appropriate

altimeter setting available before departure." As the UAV may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption is requested. 

An equivalent level of safety will be achieved by the operator confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes. As the UAVs are electric-powered, this requirement is inapplicable. In any event, given 

the contemplated operations, Stanley Scott believes that an equivalent level of safety is already 

achieved with the specific procedure preventing the UAVs accepting a take-off order if the 

battery level is below a given value. Moreover, the manufacturers have integrated low and 

critical battery level warnings and implemented a "return to home" action in these situations. 

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and current airworthiness 

certificate. 

• No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 are displayed 

at the cabin or cockpit entrance so that it is legible to passengers or crew. 

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the UAV will have immediate access to them; to the extent they are 
applicable to such UAV. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700. 

14 CFR Subpart E (91.401 - 91.417): Maintenance, Preventive Maintenance, and 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91 A07 and 91 

.409 require the aircraft to be "approved for return to service by a person authorized under 43.7" 

after maintenance and inspection. Section 91.409 requires an annual inspection for the 

issuance of an airworthiness certificate. Section 91 A 17 requires the owner or operator to keep 

records showing certain maintenance work that has been accomplished by certificated 

mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to 

service. 

Stanley Scott proposes that the maintenance of the UAVs will be accomplished by the owner or 

the operator according to the manufacturer’s user manual. Given that these section and Part 43 

apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook as referenced herein. An equivalent level of safety will be achieved 

because these small UAVs are very limited in size and will carry a small payload and operate 

only in restricted areas for limited periods of time. If mechanical issues arise the UAV can land 

immediately and will be operating from no higher than 400 feet AGL. The operator will ensure 

that the 

UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of 

any maintenance performed. Moreover, the operator is the person most familiar with the aircraft 

and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level 

of safety.